Australia’s international education regulators have issued a warning to providers over concerns that some recruitment practices may be undermining new restrictions on education agent commissions linked to onshore student transfers.
The sector alert, jointly issued by the Tertiary Education Quality and Standards Agency (TEQSA) and the Australian Skills Quality Authority (ASQA), does not introduce new rules. Instead, it reminds higher education and vocational education providers of their responsibilities under recent amendments to Australia’s international education regulatory framework and warns against attempts to bypass existing requirements.
The move highlights growing regulatory attention on the relationship between education providers, agents, and international student mobility within Australia.
New restrictions target commission-driven transfers
The latest scrutiny follows amendments to the National Code of Practice for Providers of Education and Training to Overseas Students 2018, signed by Assistant Minister for International Education Julian Hill in January 2026.
The amendments restrict registered providers from paying education agent commissions for recruiting overseas students who have already commenced studies with another provider, except in specific circumstances.
The restrictions are intended to address concerns that some international students may be encouraged to transfer between institutions because of commercial incentives rather than genuine academic needs.
However, the changes do not prevent legitimate student progression or the use of education agents. Commissions may still be paid in circumstances including where:
- the student became an accepted student of the provider before 31 March 2026;
- the commission relates to the course listed on the student’s Confirmation of Enrolment (CoE) for which their visa was granted; or
- the student begins a new course after completing their principal course of study with another provider.
The distinction is important. The policy aims to discourage unnecessary transfers while maintaining support for legitimate academic pathways within the Australian Qualifications Framework (AQF).
Regulators raise concerns over possible workarounds
In their sector alert, TEQSA and ASQA stated that they were aware of advertising and business practices that appeared inconsistent with the intention of the commission restrictions.
The regulators expressed concern that some providers or agents may attempt to preserve commission-based recruitment behaviour through alternative arrangements, such as referral incentives or third-party agreements.
The alert identified several areas requiring closer attention, including:
- referral or incentive arrangements connected to student transfers;
- advertising practices that encourage unnecessary provider changes;
- insufficient oversight of education agents and third-party partners;
- failure to declare recruitment arrangements;
- inaccurate or delayed reporting of student transfer activities;
- weak governance, monitoring, and record-keeping systems; and
- inadequate assessment of whether transferred students are academically prepared for their new courses.
TEQSA and ASQA warned that providers unable to demonstrate effective controls may face compliance assessments or regulatory action.
Industry welcomes stronger accountability
Concerns about “student poaching” have been raised across Australia’s international education sector for several years.
Industry groups have argued that competition for international students should be based on education quality, student support, and academic outcomes rather than financial incentives encouraging unnecessary movement between providers.
The Association for Australian Education Representatives in India (AAERI) has supported stronger measures to improve accountability among education agents.
Ravi Lochan Singh, managing director of Global Reach, described the restriction on commission payments for certain onshore transfers as a positive development, while noting that legitimate progression pathways remain supported.
Students moving through recognised AQF pathways — such as progressing from vocational education to higher education or from undergraduate to postgraduate study — can continue to receive assistance from education agents where appropriate.
Providers face greater responsibility for agent management
The regulatory focus reflects a broader shift in Australia’s approach to international student recruitment.
Education agents remain an important part of Australia’s international education ecosystem, particularly in overseas markets where students depend on professional guidance when selecting institutions and preparing applications.
However, the sector is facing increasing expectations that providers must actively manage their agent networks rather than relying solely on contractual arrangements.
Under the regulator expectations outlined in the alert, providers should review:
- agreements with education agents and third parties;
- incentive and referral structures;
- recruitment advertising;
- admissions and transfer procedures;
- monitoring and compliance systems; and
- internal governance arrangements.
Institutions are expected to demonstrate that decisions involving international student transfers are made in students’ best interests and support quality education outcomes.
A broader integrity agenda for international education
The focus on student transfers forms part of wider reforms aimed at strengthening integrity and sustainability in Australia’s international education sector.
Following a period of rapid growth, Australia has increased regulatory attention on areas including education quality, student protection, migration-related risks, and the role of education agents.
For providers, the message is increasingly clear: international recruitment must be supported by strong governance, transparency, and responsible partnerships.
The Educationist perspective
The latest developments illustrate a wider global trend in international education. Governments and regulators are becoming more cautious about recruitment models that prioritise enrolment growth without sufficient attention to student outcomes.
Education agents will continue to play an important role in global student mobility, but the relationship between institutions and agents is likely to become more closely scrutinised.
For universities and colleges seeking sustainable international growth, long-term success will depend less on aggressive recruitment tactics and more on academic reputation, trusted partnerships, and delivering genuine value to students.
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